Unit of Competency Mapping – Information for Teachers/Assessors – Information for Learners

FNSAML804 Mapping and Delivery Guide
Design customer due diligence policies and procedures

Version 1.0
Issue Date: May 2024


Qualification -
Unit of Competency FNSAML804 - Design customer due diligence policies and procedures
Description
Employability Skills
Learning Outcomes and Application This unit describes the skills and knowledge required to analyse requirements and design customer due diligence policies and procedures relating to the identification of customers, monitoring of customer behaviour and governance processes and controls for the customer identification process. It applies to individuals who use specialised anti-money laundering and counter terrorism financing (AML/CTF) knowledge and skills to evaluate complex information and compliance requirements and apply to relevant tasks. Individuals typically lead and review organisation wide activities, exercise significant autonomy, responsibility and accountability and contribute to the strategic goals and operations of the organisation. They review, critically analyse, consolidate and synthesise knowledge to generate ideas and provide solutions to complex problems. No licensing, legislative or certification requirements apply to this unit at the time of publication.
Duration and Setting X weeks, nominally xx hours, delivered in a classroom/online/blended learning setting.

Assessment must be conducted in a safe environment where evidence gathered demonstrates consistent performance of typical activities experienced in the AML/CTF field and include access to:

relevant legislation, regulations, standards and codes

relevant organisational records, policies and procedures.

Assessors of this unit must satisfy the requirements for assessors in applicable vocational education and training legislation, frameworks and/or standards.
Prerequisites/co-requisites
Competency Field
Development and validation strategy and guide for assessors and learners Student Learning Resources Handouts
Activities 		Slides
PPT 		Assessment 1 Assessment 2 Assessment 3 Assessment 4
Elements of Competency Performance Criteria              
Element: Design processes for customer identification
  • Design processes to collect information and documentation from different categories of clients
  • Design processes for determining the ultimate beneficial owner of assets or funds where the client is a trust or fund or wealth management company
  • Design a separate process for verifying client information and documentation
  • Establish procedures for retention and retrieval of information and documentation from clients
  • Design an assurance or oversight process to ensure all collection, verification, retention and retrieval processes comply with relevant AML/CTF rules
  • Design processes for risk rating clients based on evaluating their characteristics, including jurisdiction and nature of business or occupation, with a financial crime specific risk framework
       
Element: Design processes for identifying and monitoring customer behaviour
  • Devise a process for determining a customer’s source of wealth
  • Specify a control for identifying the source of funding for a transaction, where required
  • Design a process for analysing the products utilised by a customer and considering how that may impact their risk profile
  • Establish a procedure investigating the entities and individuals with whom a client is involved and whether this impacts their risk profile
  • Determine the risk indicators that may apply to specific customers who represent an increased risk to the organisation
  • Determine the specific monitoring, approval and review controls applicable to different client categories based on the risk that they represent for the organisation
       
Element: Design governance processes and controls for the customer due diligence processes
  • Determine the assurance governance procedures for client identification and money laundering and terror financing (ML/TF) risk processes
  • Determine the oversight framework for the customer due diligence procedure
  • Design a governance framework for customer due diligence policies and procedures
  • Design a process for ensuring that client risk assessment is consistent with the organisation’s risk appetite
  • Specify processes for ensuring that customer due diligence policies and procedures are updated to reflect changes in regulation and organisational risk appetite
  • Design and document the escalation procedure, including the escalation triggers and to whom issues will be escalated
  • Design and document the exemptions policy and procedure
       


Evidence Required

List the assessment methods to be used and the context and resources required for assessment. Copy and paste the relevant sections from the evidence guide below and then re-write these in plain English.

ELEMENT

PERFORMANCE CRITERIA

Elements describe the essential outcomes.

Performance criteria describe the performance needed to demonstrate achievement of the element.

1. Design processes for customer identification

1.1 Design processes to collect information and documentation from different categories of clients

1.2 Design processes for determining the ultimate beneficial owner of assets or funds where the client is a trust or fund or wealth management company

1.3 Design a separate process for verifying client information and documentation

1.4 Establish procedures for retention and retrieval of information and documentation from clients

1.5 Design an assurance or oversight process to ensure all collection, verification, retention and retrieval processes comply with relevant AML/CTF rules

1.6 Design processes for risk rating clients based on evaluating their characteristics, including jurisdiction and nature of business or occupation, with a financial crime specific risk framework

2. Design processes for identifying and monitoring customer behaviour

2.1 Devise a process for determining a customer’s source of wealth

2.2 Specify a control for identifying the source of funding for a transaction, where required

2.3 Design a process for analysing the products utilised by a customer and considering how that may impact their risk profile

2.4 Establish a procedure investigating the entities and individuals with whom a client is involved and whether this impacts their risk profile

2.5 Determine the risk indicators that may apply to specific customers who represent an increased risk to the organisation

2.6 Determine the specific monitoring, approval and review controls applicable to different client categories based on the risk that they represent for the organisation

3. Design governance processes and controls for the customer due diligence processes

3.1 Determine the assurance governance procedures for client identification and money laundering and terror financing (ML/TF) risk processes

3.2 Determine the oversight framework for the customer due diligence procedure

3.3 Design a governance framework for customer due diligence policies and procedures

3.4 Design a process for ensuring that client risk assessment is consistent with the organisation’s risk appetite

3.5 Specify processes for ensuring that customer due diligence policies and procedures are updated to reflect changes in regulation and organisational risk appetite

3.6 Design and document the escalation procedure, including the escalation triggers and to whom issues will be escalated

3.7 Design and document the exemptions policy and procedure

Evidence of the ability to:

design organisational processes for customer due diligence including customer identification, identifying and monitoring customer behaviour and controls for the processes

document customer due diligence processes accurately and clearly using organisational formats and protocols.

Note: If a specific volume or frequency is not stated, then evidence must be provided at least once.

To complete the unit requirements safely and effectively, the individual must:

explain the money laundering and terrorism financing (ML/TF) customer due diligence process, including customer identification, identifying and monitoring customer behaviour and controls used

explain organisational processes and procedures for documenting and implementing policies and procedures

describe assurance governance procedures for customer identification processes

outline the key features and requirements of the legislative, regulatory and industry requirements for anti-money laundering and counter terrorism financing (AML/CTF).

Submission Requirements

List each assessment task's title, type (eg project, observation/demonstration, essay, assignment, checklist) and due date here

Assessment task 1: [title]      Due date:

(add new lines for each of the assessment tasks)

Assessment Tasks

Copy and paste from the following data to produce each assessment task. Write these in plain English and spell out how, when and where the task is to be carried out, under what conditions, and what resources are needed. Include guidelines about how well the candidate has to perform a task for it to be judged satisfactory.

ELEMENT

PERFORMANCE CRITERIA

Elements describe the essential outcomes.

Performance criteria describe the performance needed to demonstrate achievement of the element.

1. Design processes for customer identification

1.1 Design processes to collect information and documentation from different categories of clients

1.2 Design processes for determining the ultimate beneficial owner of assets or funds where the client is a trust or fund or wealth management company

1.3 Design a separate process for verifying client information and documentation

1.4 Establish procedures for retention and retrieval of information and documentation from clients

1.5 Design an assurance or oversight process to ensure all collection, verification, retention and retrieval processes comply with relevant AML/CTF rules

1.6 Design processes for risk rating clients based on evaluating their characteristics, including jurisdiction and nature of business or occupation, with a financial crime specific risk framework

2. Design processes for identifying and monitoring customer behaviour

2.1 Devise a process for determining a customer’s source of wealth

2.2 Specify a control for identifying the source of funding for a transaction, where required

2.3 Design a process for analysing the products utilised by a customer and considering how that may impact their risk profile

2.4 Establish a procedure investigating the entities and individuals with whom a client is involved and whether this impacts their risk profile

2.5 Determine the risk indicators that may apply to specific customers who represent an increased risk to the organisation

2.6 Determine the specific monitoring, approval and review controls applicable to different client categories based on the risk that they represent for the organisation

3. Design governance processes and controls for the customer due diligence processes

3.1 Determine the assurance governance procedures for client identification and money laundering and terror financing (ML/TF) risk processes

3.2 Determine the oversight framework for the customer due diligence procedure

3.3 Design a governance framework for customer due diligence policies and procedures

3.4 Design a process for ensuring that client risk assessment is consistent with the organisation’s risk appetite

3.5 Specify processes for ensuring that customer due diligence policies and procedures are updated to reflect changes in regulation and organisational risk appetite

3.6 Design and document the escalation procedure, including the escalation triggers and to whom issues will be escalated

3.7 Design and document the exemptions policy and procedure

Copy and paste from the following performance criteria to create an observation checklist for each task. When you have finished writing your assessment tool every one of these must have been addressed, preferably several times in a variety of contexts. To ensure this occurs download the assessment matrix for the unit; enter each assessment task as a column header and place check marks against each performance criteria that task addresses.

Observation Checklist

Tasks to be observed according to workplace/college/TAFE policy and procedures, relevant legislation and Codes of Practice Yes No Comments/feedback
Design processes to collect information and documentation from different categories of clients 
Design processes for determining the ultimate beneficial owner of assets or funds where the client is a trust or fund or wealth management company 
Design a separate process for verifying client information and documentation 
Establish procedures for retention and retrieval of information and documentation from clients 
Design an assurance or oversight process to ensure all collection, verification, retention and retrieval processes comply with relevant AML/CTF rules 
Design processes for risk rating clients based on evaluating their characteristics, including jurisdiction and nature of business or occupation, with a financial crime specific risk framework 
Devise a process for determining a customer’s source of wealth 
Specify a control for identifying the source of funding for a transaction, where required 
Design a process for analysing the products utilised by a customer and considering how that may impact their risk profile 
Establish a procedure investigating the entities and individuals with whom a client is involved and whether this impacts their risk profile 
Determine the risk indicators that may apply to specific customers who represent an increased risk to the organisation 
Determine the specific monitoring, approval and review controls applicable to different client categories based on the risk that they represent for the organisation 
Determine the assurance governance procedures for client identification and money laundering and terror financing (ML/TF) risk processes 
Determine the oversight framework for the customer due diligence procedure 
Design a governance framework for customer due diligence policies and procedures 
Design a process for ensuring that client risk assessment is consistent with the organisation’s risk appetite 
Specify processes for ensuring that customer due diligence policies and procedures are updated to reflect changes in regulation and organisational risk appetite 
Design and document the escalation procedure, including the escalation triggers and to whom issues will be escalated 
Design and document the exemptions policy and procedure 

Forms

Assessment Cover Sheet

FNSAML804 - Design customer due diligence policies and procedures
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Assessment Record Sheet

FNSAML804 - Design customer due diligence policies and procedures

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